KVKK Enlightenment Text
This Enlightenment Text has been prepared in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform, published in the Official Gazette on March 10, 2018. Its purpose is to inform you — as a data subject — about the processing of your personal data by TogetherHR Executive Search & Advisory (“TogetherHR” or “Data Controller”).
1. Identity of the Data Controller
In accordance with KVKK, the data controller responsible for the processing of your personal data is:
TogetherHR Executive Search & Advisory
Address: [registered business address]
Email: info@2getherhr.com
Website: 2getherhr.com
TogetherHR is a sector-focused boutique executive search firm specializing in leadership roles across luxury hospitality, lifestyle, fashion, and leisure industries, operating from Turkey with international scope.
2. Categories of Personal Data Processed
TogetherHR may process the following categories of personal data depending on your relationship with us (candidate, client representative, or website visitor):
| Data Category | Examples | Data Subjects |
|---|---|---|
| Identity Data | Full name, title, nationality | Candidates, Clients |
| Contact Data | Email address, phone number, business address | Candidates, Clients, Visitors |
| Professional Data | CV, work history, current and prior positions, employers, responsibilities, qualifications, certifications | Candidates |
| Education Data | Degrees, institutions, graduation dates, academic achievements | Candidates |
| Financial Expectations | Compensation expectations, benefits requirements | Candidates |
| Reference Data | Names and contact information of professional references (with consent) | Candidates |
| Client Business Data | Company name, role specifications, organizational requirements, engagement details | Clients |
| Digital Interaction Data | IP address, browser type, device information, pages visited, cookies | Website Visitors |
| Communication Data | Information submitted via contact forms, email correspondence, meeting notes | All |
Sensitive personal data: TogetherHR does not intentionally collect or process special categories of personal data (sensitive data) as defined in KVKK Article 6, including data relating to race, ethnicity, political opinion, philosophical belief, religion, appearance, membership in associations, health, sexual life, criminal convictions, or biometric/genetic data. If such data is inadvertently received, it will be deleted immediately.
3. Purposes of Processing
Your personal data is processed by TogetherHR for the following purposes, in accordance with KVKK Articles 5 and 6:
Executive Search & Recruitment
- Identifying, evaluating, and presenting candidates for leadership positions
- Managing the end-to-end executive search process in collaboration with client organizations
- Maintaining and developing our leadership talent network within luxury hospitality, lifestyle, fashion, and leisure sectors
- Following talent market movements and leadership availability within focus sectors
Client Relationship Management
- Fulfilling contractual obligations under executive search and employer branding consulting engagements
- Providing strategic advisory on leadership talent landscape and organizational needs
- Communicating with client representatives regarding engagement progress and deliverables
Website Operations & Communication
- Responding to inquiries submitted through the “Start a Conversation” form or other contact channels
- Ensuring the technical functionality and security of our website
- Analyzing website usage to improve content and user experience
Legal & Regulatory Compliance
- Fulfilling legal and regulatory obligations under Turkish law
- Establishing, exercising, or defending legal claims where necessary
4. Legal Bases for Processing
TogetherHR processes personal data on the following legal grounds as set out in KVKK Article 5(2):
| Legal Basis (KVKK Art. 5/2) | Application |
|---|---|
| Explicit consent of the data subject | Processing candidate CVs and professional data for executive search purposes; sharing candidate information with specific client organizations; sending sector insights and communications |
| Necessary for the performance of a contract | Processing data required to fulfill executive search and employer branding consulting agreements with clients |
| Necessary for compliance with a legal obligation | Retaining data as required by Turkish commercial law, tax regulations, and other applicable legislation |
| Data made public by the data subject | Processing professional information that candidates have made publicly available on professional networks, company websites, or industry directories |
| Necessary for the legitimate interests of the data controller | Maintaining our leadership talent network; analyzing website traffic; improving services; ensuring information security — provided this does not override the fundamental rights of the data subject |
| Necessary for the establishment, exercise, or defense of a right | Processing data where required to establish, exercise, or defend legal claims |
5. Transfer of Personal Data
In accordance with KVKK Articles 8 and 9, your personal data may be transferred to the following recipients:
Domestic Transfers (KVKK Art. 8)
- Client organizations — Candidate data shared within the scope of an active executive search engagement, with the candidate’s knowledge
- Legal and regulatory authorities — Where required by law, court order, or regulatory request
- Service providers — IT infrastructure, website hosting, and analytics providers operating under data processing agreements
- Professional advisors — Legal, tax, and financial advisors bound by confidentiality obligations
International Transfers (KVKK Art. 9)
Given the international nature of executive search, personal data may be transferred to countries outside of Turkey in the following circumstances:
- When a client organization is based outside Turkey and the search engagement requires cross-border data sharing
- When third-party service providers (such as cloud hosting or analytics platforms) process data outside Turkey
International transfers are made with appropriate safeguards in accordance with KVKK Article 9, including explicit consent, adequacy decisions by the Personal Data Protection Board (“Kurul”), or commitments by the receiving party to provide adequate protection.
6. Methods & Legal Grounds for Data Collection
Personal data is collected through the following channels:
- Direct communication — Email, phone, in-person meetings, and correspondence initiated by you or by TogetherHR as part of the executive search process
- Website forms — Contact forms and “Start a Conversation” requests submitted on our website
- Professional networks — Publicly available profiles and professional directories within our focus sectors
- Client and industry referrals — Information provided by client organizations, professional references, and industry contacts
- Automated means — Cookies and similar technologies used on our website (see our Cookie Policy for details)
Data is collected on the legal grounds specified in Section 4 above and in accordance with the general principles outlined in KVKK Article 4 (lawfulness, fairness, accuracy, purpose limitation, data minimization, and limited retention).
7. Your Rights Under KVKK Article 11
As a data subject, you have the following rights under Article 11 of KVKK:
a) Right to Know
Learn whether your personal data is being processed
b) Right to Information
Request information about the processing if your data has been processed
c) Right to Purpose
Learn the purpose of processing and whether data is used in accordance with that purpose
d) Right to Know Recipients
Know the third parties to whom your personal data has been transferred, domestically or abroad
e) Right to Correction
Request correction of incomplete or inaccurate personal data
f) Right to Deletion
Request erasure or destruction of personal data under conditions set out in KVKK Article 7
g) Right to Notification
Request that corrections or deletions are notified to third parties to whom data was transferred
h) Right to Object
Object to outcomes arising from exclusively automated analysis of your data
i) Right to Compensation
Claim compensation for damages arising from unlawful processing of your personal data
8. How to Exercise Your Rights
To exercise your rights under KVKK Article 11, you may submit your request to TogetherHR using one of the following methods:
- Written application: A signed petition sent to our registered address via post or delivered in person
- Email: A request sent from your registered email address to our contact email below
- Registered electronic mail (KEP): If available, through the KEP system
Your application must include:
- Your full name, T.R. identity number (for Turkish citizens) or passport/ID number (for foreign nationals)
- Your residential or business address for notification purposes
- Your email address and/or phone number
- A clear description of the right(s) you wish to exercise and the subject of your request
- Supporting documents, if applicable
Response timeline: In accordance with KVKK Article 13, TogetherHR will respond to your request free of charge within 30 days at the latest. If the request requires additional investigation, the response period may be extended by an additional 30 days, in which case you will be informed of the reason for the extension. If a response involves costs (e.g., providing data on physical media), fees set by the Personal Data Protection Board may apply.
Data Controller Contact
TogetherHR Executive Search & Advisory
Address: [registered business address]
Email: info@2getherhr.com
Website: 2getherhr.com
If your request is not resolved satisfactorily, you have the right to file a complaint with the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu — kvkk.gov.tr).